Interpretation ID: nht71-1.8

DATE: 02/18/71

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Strick Corporation

TITLE: FMVSR INTERPRETATION

TEXT: Mr. Toms has asked me to reply to your letter of December 3, 1971, in which you enclosed a drawing of a certification label you intend to use to fulfill the amended requirements of Part 567 of Title 45 of the Code of Federal Regulations.

In a telephone conversation with you, Mr. George Shifflett of my staff has explained that the (Illegible Word) used on your proposed label does not fulfill the requirements. The Certification regulations require each vehicle to be labeled with specific information applicable to that vehicle. The information is to be presented in a specific order and manner. We do not consider a multipurpose label such as the one you have submitted to be consistent with those requirements. The label for each vehicle should reflect information only for that vehicle.

Multiple GVWR and GAWR are permissible as specified in the amendments to the regulation published in the Federal Register on December 19, 1971. A copy of that publication is enclosed. (Illegible Word) multiple listings are to be applied to the label in keeping with the format outlines in the amendment. For example:

GAWR:

Front - 10,000 with 7.50 x 15E Tires 13,000 with 8.25 x 15F Tires 15,000 with 8.25 x 15X Steel Cord Tires

Rear - 19,000 with 7.50 x 15E Tires 13,000 with 8.25 x 15F Tires 15,000 with 8.25 x 15X Steel Cord Tires

The other nonrequired information in the body of your label, "when load is properly distributed" and "based on tire capacity for each axle (Illegible Word) of position," should be removed from its present location on the label. Section 567.4(g) requires all information on the label to be placed in the order listed in all information. However, we have no objection if you wish to add the additional information to the bottom of the label, below the required information. We would expect vehicles produced by your company to bear conforming labels by April 1, 1972.

If you have further questions I will be pleased to answer them.

Sincerely,

Enclosure